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Kassin Compl1 Final

Kassin Compl1 Final



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Published by SHIFrankel
2 N.J. Mayors, Several Rabbis Arrested: Feds arrest mayors of 2 NJ cities, lawmaker in broad corruption
2 N.J. Mayors, Several Rabbis Arrested: Feds arrest mayors of 2 NJ cities, lawmaker in broad corruption

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Published by: SHIFrankel on Jul 23, 2009
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v. :SAUL KASSIN :Mag. No. 09-3610I, Robert J. Cooke, being duly sworn, state that the following is true and correct to thebest of my knowledge and belief.From in or about June 2007 to in or about December 2008, in Monmouth County, in theDistrict of New Jersey, and elsewhere, defendant SAUL KASSIN did:
knowingly and willfully conspire with others to conduct and attempt to conduct financialtransactions involving property represented to be the proceeds of specified unlawful activity,specifically, bankruptcy fraud and trafficking in counterfeit goods, with the intent to conceal anddisguise the nature, location, source, ownership, and control of the property believed to beproceeds of specified unlawful activity, contrary to Title 18, United States Code, Section1956(a)(3).
 In violation of Title 18, United States Code, Section 1956(h).I further state that I am a Special Agent with the Federal Bureau of Investigation, and that thiscomplaint is based on the following facts:SEE ATTACHMENT Acontinued on the attached page and made a part hereof._______________________________Robert J. Cooke, Special AgentFederal Bureau of InvestigationSworn to before me and subscribed in my presence,July , 2009, at Newark, New JerseyH
Signature of Judicial Officer
Attachment A
I, Robert J. Cooke, am a Special Agent with the FederalBureau of Investigation (“FBI”). I have personally participatedin this investigation and am aware of the facts contained herein,based upon my own participation in this investigation, as well asinformation provided to me by other law enforcement officers.Because this Attachment A is submitted for the limited purpose ofestablishing probable cause, I have not included herein thedetails of every aspect of this investigation. Statementsattributable to individuals contained in this Attachment arerelated in substance and in part, except where otherwiseindicated. All contacts discussed herein were recorded, exceptas otherwise indicated.1. Defendant Saul Kassin, a resident of Brooklyn, New York,is the Chief Rabbi of Sharee Zion, a synagogue located on OceanParkway in Brooklyn (hereinafter, “defendant KASSIN”). DefendantKASSIN operated a charitable tax-exempt organization inconjunction with his synagogue (hereinafter, “defendant KASSIN’sCharitable Organization”). A check with the New JerseyDepartment of Banking and Insurance and the New York StateDepartment of Banking has revealed that defendant KASSIN does nothold a license to transmit or remit money.2. At all times relevant to this Complaint:(a)There was a coconspirator named Edmond Nahum(hereinafter, “Coconspirator Nahum”) who was the principal rabbiof Deal Synagogue, a synagogue located in Deal, New Jersey. Acheck with the New Jersey Department of Banking and Insurance andthe New York State Department of Banking has revealed thatCoconspirator Nahum does not hold a license to transmit or remitmoney;(b)There was an individual named Eliahu Ben Haim, a/k/aEli Ben Haim (hereinafter, “Ben Haim”) who was the principalrabbi of Congregation Ohel Yaacob, a synagogue located in Deal.Ben Haim operated several charitable tax-exempt organizations inconjunction with his synagogue, including one called CongregationOhel Eliahu (hereinafter, “COE”) and another called Friends ofYachave Da’at. A check with the New Jersey Department of Bankingand Insurance and the New York State Department of Banking hasrevealed that Ben Haim does not hold a license to transmit orremit money; and
(c)There was a cooperating witness (the “CW”) who had beencharged in a federal criminal complaint with bank fraud in orabout May 2006. Pursuant to the FBI’s investigation and underits direction, the CW from time to time represented that the CWpurportedly was engaged in illegal businesses and schemesincluding bank fraud, trafficking in counterfeit goods andconcealing assets and monies in connection with bankruptcyproceedings.3.On or about June 20, 2007, Coconspirator Nahum met withthe CW in Coconspirator Nahum's
office in Deal. During thismeeting, Coconspirator Nahum received a check from the CW in theamount of $10,000 made payable to defendant KASSIN’s CharitableOrganization. The CW indicated that the funds from this checkrepresented monies that the CW was owed by another individual,and that this other individual wished to launder the moneythrough a charitable organization. The CW also informedCoconspirator Nahum that “the guy gave it to me because he wantsa write off, like everybody else.” Later in the conversation,Coconspirator Nahum described how he put checks through defendantKASSIN’s Charitable Organization and would receive checks inreturn. When the CW noted that the people who had initiallyprovided the checks to Coconspirator Nahum did so because “thepeople want the write offs,” Coconspirator Nahum responded“[e]xactly.” Coconspirator Nahum also confirmed that defendantKASSIN received many checks each day, prompting the CW to ask“hundreds of thousands a week, no?” Coconspirator Nahum replied“[a]t least - more,” and noted that defendant KASSIN had a staffto help him with the accounting. Coconspirator Nahum alsoconfirmed that defendant KASSIN charged a fee for moving checksthrough his charitable account, and did not disagree when the CWsuggested that the fee would likely be a five to ten percentcommission. Prior to the CW’s departure,
Coconspirator Nahum putthe check the CW had provided to him into a stamped envelope tobe mailed to “Rabbi Saul J. KASSIN,” at an address in “Brooklyn,N.Y.” Coconspirator Nahum also put within this envelope astamped envelope addressed to the CW along with a note to returnto the CW a check in the amount of $9,000 made payable to eithera specified company - in reality, a fictitious company set up bythe FBI for the purpose of enabling the CW to launder moneyrepresented to be the proceeds of illegal activities - or to oneof Ben Haim's charitable organizations.4. On or about June 26, 2007, Coconspirator Nahum receiveda phone call from the CW who asked Coconspirator Nahum if he knew“whether Rabbi Kassin got that check yet,” a reference to the$10,000 check that the CW had provided to Coconspirator Nahum onor about June 20, 2007. Coconspirator Nahum informed the CW that

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